IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
PLR 1138010: IRS grants extra time for an LLC to elect corporate tax treatment
A limited liability company intended to be treated as an association taxable as a corporation for federal tax purposes but did not timely file Form 8832. The company asked for relief under Treas.…
PLR 1138009: IRS grants extra time for a foreign LLC to elect disregarded-entity status
A foreign eligible entity wholly owned by another entity intended to be treated as a disregarded entity but did not timely file Form 8832. The owner asked for relief under Treas. Reg. § 301.9100-3.…
PLR 1138005: IRS grants extra time for a foreign entity to elect partnership status
A foreign eligible entity intended to be classified as a partnership for federal tax purposes but did not timely file Form 8832. The entity asked for relief under Treas. Reg. § 301.9100-3. The IRS…
PLR 1137010: IRS grants more time to elect disregarded-entity treatment
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on a…
PLR 1136010: Foreign entity granted more time to elect partnership classification
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity had failed to file the election on time, and the IRS…
PLR 1135028: IRS grants late election to treat a foreign entity as disregarded
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on an…
PLR 1135027: IRS grants late election to treat a foreign entity as disregarded
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on an…
PLR 1135026: IRS grants late election to treat a foreign entity as disregarded
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make the election effective on an…
PLR 1135020: IRS grants extra time for a foreign entity to elect partnership classification
The foreign entity asked the IRS for more time to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The entity intended the classification to apply from an earlier…
PLR 1134013: IRS grants late entity-classification election relief
A foreign entity that had been treated consistently as disregarded for federal tax purposes failed to file its entity-classification election on time. The IRS found that the taxpayer acted…
PLR 1133002: Foreign entity granted more time to elect partnership status
The IRS granted a foreign eligible entity 120 additional days to file Form 8832 and elect partnership classification for federal tax purposes. The entity had failed to make the election by the…
PLR 1132004: Late entity-classification election granted for a limited liability partnership
The IRS granted a limited liability partnership 120 more days to file Form 8832 and elect partnership treatment for federal tax purposes. The entity intended to make the election effective when it…
PLR 1129032: IRS grants extra time for an entity classification election
An eligible entity asked for more time to file Form 8832 and elect to be treated as an association taxable as a corporation for federal tax purposes. The entity intended the election to be effective…
PLR 1127008: IRS grants late-election relief for LLC classification and S corporation status
An LLC asked for relief after it failed to timely file its entity classification election and S corporation election. The IRS granted 120 days to file Form 8832 to elect association treatment for…
PLR 1126024: LLC received more time to elect partnership classification
The IRS granted a limited liability company an extension to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The company intended to make the election effective…
PLR 1125010: Extension of time granted to elect partnership classification
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity intended to make the election by its…
PLR 1124017: IRS grants late election relief for disregarded-entity status
The IRS granted an organization 120 additional days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The organization had failed to file the form on time…
PLR 1124016: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124015: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124014: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124013: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124012: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124011: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124010: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1124009: IRS grants late election relief for a foreign entity
The IRS granted a foreign entity 120 additional days to file Form 8832 and elect to be treated as disregarded for federal tax purposes. The entity was wholly owned by a parent and had intended to…
PLR 1123006: IRS grants more time to elect corporate tax classification
A foreign entity asked for more time to file Form 8832 to be treated as an association taxable as a corporation for federal tax purposes. The entity had intended to be treated as a partnership but…
PLR 1123002: IRS grants more time to elect association tax treatment
An entity asked for more time to file Form 8832 to be classified as an association taxable as a corporation for federal tax purposes. It had intended to make the election effective on its formation…
PLR 1122010: IRS grants late entity-classification elections for foreign entities
The IRS granted two foreign entities 120 days to file Form 8832 elections to be treated as associations taxable as corporations for federal tax purposes. The entities were eligible to make the…
PLR 1120007: late entity-classification election granted
The IRS granted an entity 120 days to make a late election to be classified as an association taxable as a corporation for federal tax purposes. The entity had intended the classification to apply…
PLR 1119019: foreign entity may make a late election to be treated as a corporation
A foreign entity that had been treated as a partnership asked for more time to elect classification as an association taxable as a corporation after a change in ownership. The entity had been…
PLR 1119012: Foreign entities granted time to elect disregarded-entity status
Eleven foreign entities asked for more time to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. The entities were eligible to make the elections but had not…
PLR 1119008: Trust income for public retiree health benefits is excluded under section 115
A state-created trust pooled and invested assets set aside by local public agencies for retiree health benefits. The trust was limited to governmental participants, and its assets could be used only…
PLR 1117018: IRS grants late-election relief for foreign entity classification
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity had intended to make that…
PLR 1117003: Extension for a late disregarded-entity election
The IRS considered a foreign eligible entity that intended to be treated as disregarded for federal tax purposes but did not timely file Form 8832. The IRS found that the requirements for relief…
PLR 1117002: Foreign pension entity classified as a trust for federal tax purposes
The IRS considered whether an entity formed under foreign law to provide disability, old age, and death benefits to covered employees and their beneficiaries should be classified as a trust for…
PLR 1116011: IRS allowed an LLC to change to disregarded-entity status
The IRS considered an eligible limited liability company that had elected to be treated as an association taxable as a corporation. The taxpayer represented that more than 50 percent of the…
PLR 1114012: IRS grants 120 days to make a late entity-classification election
The IRS granted an entity 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes, effective on the requested earlier date. The entity had failed to file…
PLR 1113013: IRS grants late entity classification elections for six foreign entities
The IRS gave six foreign entities 120 days to file Form 8832 elections to be treated as disregarded entities for federal tax purposes. The entities had not timely filed valid elections but had…
PLR 1113012: IRS classifies a bankruptcy trust as a liquidating trust
The IRS ruled that a trust formed under a Chapter 11 bankruptcy plan qualified as a liquidating trust for federal income tax purposes. The trust was created to liquidate and distribute assets, and…
PLR 1110010: IRS grants late election relief for a foreign entity to be treated as disregarded
The IRS granted a foreign eligible entity an additional 120 days to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was wholly owned by another…
PLR 1108019: Foreign entity granted more time to elect partnership classification
The IRS granted a foreign entity an extension of time to file Form 8832 and elect to be classified as a partnership for federal tax purposes. The entity was eligible to make the election but had…
PLR 1108007: Foreign entity receives more time to elect disregarded status
A foreign eligible entity intended to be treated as disregarded for federal tax purposes but failed to timely file Form 8832. The IRS concluded that the requirements for late-election relief were…
CCA 1104042: REIT election requires corporate rules for an assessment extension
Chief Counsel advised that a statutory trust that elected REIT treatment remained classified as an association taxable as a corporation for purposes of signing a consent to extend the assessment…
PLR 1104026: IRS grants a foreign entity more time to elect partnership status
A foreign entity asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity said it intended to make the election effective when it was…
PLR 1104011: IRS grants more time to elect association classification
A business entity asked for more time to file Form 8832 and elect to be classified as an association taxable as a corporation for federal tax purposes. The entity intended the election to be…
PLR 1104010: IRS grants a foreign entity more time to elect partnership classification
A foreign entity asked for more time to file Form 8832 and elect to be treated as a partnership for federal tax purposes. The entity failed to file the form by the requested effective date. The IRS…
PLR 1104007: IRS grants more time to elect disregarded entity status
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election effective on…
PLR 1104006: IRS grants more time to elect disregarded entity status
A foreign eligible entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity was eligible to make the election effective on…
PLR 1102054: IRS grants more time to elect disregarded-entity treatment
A foreign entity asked for more time to file Form 8832 and elect to be treated as a disregarded entity for federal tax purposes. The entity intended to make the election but missed the filing…
PLR 1102041: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102040: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102039: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102038: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102037: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102036: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102035: IRS grants extra time for a foreign entity to elect disregarded-entity status
The foreign entity was eligible to elect its federal tax classification, but it did not timely file Form 8832 to be treated as a disregarded entity. The IRS determined that the requirements for…
PLR 1102026: IRS grants a partnership more time to make a section 754 election
A limited partnership asked for extra time to make a section 754 election after a partner died and the partnership missed the filing deadline. The IRS granted an extension of 120 days from the date…
PLR 1102025: IRS grants an LLC more time to make a section 754 election
A limited liability company treated as a partnership for federal tax purposes asked for extra time to make a section 754 election after a partner died and the company missed the filing deadline. The…
PLR 1102002: IRS grants more time to file a disregarded-entity election
A foreign entity intended to be treated as a disregarded entity for federal tax purposes but did not timely file Form 8832. The IRS granted the entity an additional 120 days from the ruling date to…
PLR 1102001: IRS grants more time to file a disregarded-entity election
A foreign entity intended to be treated as a disregarded entity for federal tax purposes but did not timely file Form 8832. The IRS granted the entity an additional 120 days from the ruling date to…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.